36 CFR Parts 1190 and 1191 ADA and ABA Accessibility Guidelines - Preamble (Discussion of Comments and Changes)

408 Limited-Use/Limited-Application Elevators

Section 408 provides requirements for limited-use/limited-application (LULA) elevators which correspond to section 407.4 in the proposed rule. LULA elevators are typically smaller and slower than other passenger elevators and are used for low-traffic, low-rise installations. This section provides specific criteria for these elevators and also references various provisions for standard elevators covered in section 407. Thus, some changes discussed above for standard elevators also pertain to LULA elevators as well. For example, the revision to the height of call buttons in section 407.2.1.1 (which are now subject to the basic reach range requirements instead of the previously specified range of 35 to 48 inches) also applies to LULA elevators. Additional changes in the final rule that are substantive in nature pertain to hoistways, car controls, and car sizes.

Comment. Some individuals and disability groups opposed the allowance of LULA elevators due to concerns about their size and accessibility. Industry, facility operators, designers and some disability groups strongly supported LULA elevators as an alternative where a standard elevator is not required.

Response. The Board has retained provisions for LULA elevators which are only permitted in facilities not required to have any elevator or as an alternative to platform lifts (206.6). Since this kind of elevator requires less space and costs less than standard elevators, LULA elevators will provide a more viable option where a form of vertical access would otherwise not be provided. The technical criteria for LULA elevators specify minimum car sizes that ensure adequate accessibility. In addition, they are required to comply with the applicable section of the elevator safety code (ASME/ANSI A17.1, Chapter XXV).

Comment. Requirements for standard elevators require that the main entry level be labeled by a tactile star at the hoistway (407.2.3.1). In the proposed rule, such a requirement was not included for LULA elevators. Comments suggested that such a requirement be included in the final rule for consistency.

Response. Requirements for hoistway signs for LULA elevators in section 408.2.3 have been replaced with a reference to corresponding requirements for standard elevators in section 407.2.3.1. This provision includes a requirement for a tactile star at the hoistway of the main entry level.

The guidelines specify that LULA elevator cars be at least 42 inches wide and 54 inches deep with a door on the narrow end providing at least 32 inches clear width (408.4.1). In the final rule, the Board has added alternate dimensions which are substantively consistent with the latest edition of the ANSI A117.1 standard. These dimensions permit a car at least 51 inches by 51 inches provided that the door has a clear width of at least 36 inches (408.4.1, Exception 1).

Residential dwelling units may be equipped with either a LULA elevator or a private residential elevator instead of a standard passenger elevator (206.6). Section 409 provides requirements for private residential elevators, which were located at section 1102.7 in the proposed rule. In the final rule, call buttons are subject to requirements in section 309 for operable parts, including clear floor space (309.2), height (309.3), and operation (309.4) according to section 409.2. In the proposed rule, they were subject only to requirements for height. In addition, the Board has applied requirements for the operation of operable parts (309.4) to controls (409.4.6) and the operable parts of emergency communication systems (409.4.7.2). No other substantive changes have been made to this section.